Notice of Privacy Practices

1. Who We Are (ACE Designation)

This Notice describes the privacy practices of the entities participating in the OpenLoop Affiliated Covered Entity ("ACE"), including OpenLoop Healthcare Partners PC, OpenLoop Healthcare Partners California, PC, and Untitled Health PLLC. For purposes of complying with HIPAA, the above-designated entities, which are under common ownership and control, have designated themselves an ACE. ACE participants may share your PHI with each other as needed to carry out treatment, payment, and health care operations. These affiliated covered entities have a designated single Privacy Officer responsible for HIPAA compliance across all ACE participants.

2. Your Rights

When it comes to your health information, you have certain rights. You have the right to:

• Get an electronic or paper copy of your medical record. You can ask to see or get a copy of your medical record and other health information we have about you. We will provide a copy or a summary, usually within 30 days of your request, and may charge a reasonable, cost-based fee.
• Ask us to correct your medical record if you think it is incorrect or incomplete. We may say "no" to your request, but we will tell you why in writing within 60 days.
• Request confidential communications — for example, ask us to contact you at a specific phone number or address. We will say "yes" to all reasonable requests.
• Ask us to limit what we use or share for treatment, payment, or our operations. We are not required to agree, and may say "no" if it would affect your care. If you pay out-of-pocket in full for a service, you can ask us not to share that information with your health insurer for payment or operations, and we will say "yes" unless a law requires us to share it.
• Get a list (accounting) of the times we have shared your health information for the six years prior to your request, who we shared it with, and why (excluding disclosures for treatment, payment, and health care operations and certain others). One accounting per year is free.
• Get a paper copy of this Notice at any time, even if you agreed to receive it electronically.
• Choose someone to act for you. If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
• File a complaint if you feel your privacy rights have been violated, without fear of retaliation.

3. Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us and we will follow your instructions.

You have both the right and choice to tell us to: share information with your family, close friends, or others involved in your care; share information in a disaster relief situation; or include your information in a hospital directory. If you are not able to tell us your preference — for example, if you are unconscious — we may go ahead and share your information if we believe it is in your best interest, or when needed to lessen a serious and imminent threat to health or safety.

We never share your information in the following cases unless you give us written permission: marketing purposes (we will obtain your HIPAA authorization before using your information for marketing); the sale of your information; and most sharing of psychotherapy notes. In the case of fundraising, we may contact you, but you can tell us not to contact you again by emailing our Privacy Office at privacy@openloophealth.com.

4. Our Uses and Disclosures

We typically use or share your health information in the following ways:

• Treat you — we can use your health information and share it with other professionals who are treating you.
• Run our organization — we can use and share your health information to run our practice, improve your care, and contact you when necessary (for example, appointment reminders by email or text). We use artificial intelligence and machine learning tools, in compliance with HIPAA and other applicable laws, to improve our services and clinical workflows; these tools do not replace a licensed health care professional's clinical judgment.
• Bill for your services — we can use and share your health information to bill and get payment from health plans or other entities.

We are also allowed or required to share your information in other ways — usually in ways that contribute to the public good — subject to conditions in the law. These include: helping with public health and safety issues (such as preventing disease, product recalls, reporting adverse reactions to medications, or reporting suspected abuse, neglect, or domestic violence); doing research; complying with the law; responding to organ and tissue donation requests; working with a medical examiner or funeral director; addressing workers' compensation, law enforcement, and other government requests; and responding to lawsuits and legal actions.

5. Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information — without unreasonable delay and no later than 60 days after discovery, as required by law.
• Where state laws require greater privacy protections than HIPAA, we will follow state law.
• We must follow the duties and privacy practices described in this Notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time by notifying our Privacy Office in writing.

6. Changes to the Terms of This Notice

We can change the terms of this Notice, and the changes will apply to all information we have about you. The new Notice will be available upon request, in our office, and on our website.

7. Complaints and Contact

You can complain if you feel we have violated your rights by contacting our Privacy Officer using the information below. You can also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

Privacy Officer: Justin Pingel. Phone: (844) 819-7956. Email: privacy@openloophealth.com. You can exercise any of the rights described in this Notice by emailing privacy@openloophealth.com.